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Gm, and happy Friday! BTC is taking a breather after gaining 10% over the past week. The next catalyst could come from Jackson Hole, where Kevin Warsh delivers his first keynote as Fed chair today.
Meanwhile, Washington may be preparing to reopen a door crypto thought had closed after 2017. New SEC proposals would give projects a path to sell tokens to US retail investors and eventually leave the investment contract regime. We look at whether compliant ICOs are about to return and which parts of the market stand to benefit.
BTC leads the benchmarks at 10.0% on the week against 1.8% for gold, 0.9% for the NASDAQ 100, and 0.8% for the S&P 500. Over the past month, BTC is up 25.7%, while gold has gained 15.6%.
BTC ETF flows over the last week have totaled over $3B. This is the first time BTC has had eight consecutive days on net inflows since April 2026.
Similarly, ETH ETF flows over the last week were over $1.2B. Yesterday marked the 12th day of consecutive inflows, the first time in nearly one year (not since July 2025).
Other notable mentions over the last week were SOL ($115M), XRP ($92M), and HYPE ($50M), highlighting the broadening demand beyond BTC and ETH.
Strong performance and sustained ETF inflows point to renewed institutional participation across the crypto market and add another tailwind to the recent turnaround.
Reg Crypto: the exit is the point
The SEC's proposal is the first forward-looking framework the Commission has produced for token issuance. For a full summary of the proposal, see here. To quickly summarize, it creates three pathways that did not exist before. Subpart B lets an issuer distribute up to $5M over four years on a Form NOR filing, with website disclosures and no financial statements, no investor limits and no US-domicile test.
Subpart C ports Regulation A into crypto: up to $20M per 12 months on Form 1-CRYPTO, or $75M with audited financials, SEC qualification and a 10% income/net-worth cap on non-accredited buyers. Subpart D is the off-ramp: file a Form TR certifying that the essential managerial efforts you promised are complete or permanently ceased, and the covered investment contract ends.
The most consequential line in the release is the definition of essential managerial efforts. Once a network is functional, securing, maintaining, improving or funding its development doesn't count. There is no decentralization requirement, only functionality plus promises fulfilled. Ongoing work doesn't re-trigger Howey.
Concerns
Rule 101(a) makes the exemptions non-exclusive, which creates an obvious path around the disclosure ladder. File for the startup exemption, distribute $5M to retail, then raise the rest through a Reg D private placement to accredited investors. The fundraising exemption, with its required disclosures, audited financials, SEC qualification and ongoing reporting, is never needed. So a rational structure for an issuer is to grab the startup exemption but avoid the more burdensome costs that come with the fundraising paths. This structure reduces disclosure requirements, provides greater certainty when raising from VCs and limits the number of KYC checks required.
If the issuer pursues the fundraising exemptions, it’s great that we will have disclosure requirements, but those are only for the issuer. The proposal should add a protocol-level disclosure category; at the end of the day, that’s what’s tied to the asset investors are interested in. A separate protocol-level category (protocol financials like revenue, costs, balance sheet, etc.) would surface what actually drives the asset. This data already exists and it would be beneficial to investors and issuers alike. The issuer financials are also important, as they can help with offchain data that doesn’t make its way into a protocol report (like market maker arrangements, related party arrangements, or whether the issuer is selling tokens to pay for fake usage). BOTH are needed.
There's also a disclosure cliff at the exit. Once the contract ends, the token is a commodity and the Rule 103 obligations fall away entirely. Whether the CFTC should pick up a disclosure requirement at that point is worth asking, because the market's need for information doesn't end when the SEC's jurisdiction does. Would the exit add a premium or discount? No more regulatory burdens but investors get less information about the project. Maybe the top projects continue to disclose after exit (voluntarily, of course, but we see how the industry has fared under self-regulation).
Because the exit is based on promises, the incentive is to make as few of them as possible and clear them fast. One could argue that [XYZ] chain has fulfilled its promises once it has a fast, functioning network, allowing it to exit the investment contract before starting the real work. To avoid this, the concept of representations should be broadened to encompass the full body of an issuer's statements and conduct, not only what lands in the Rule 103 filing. Moreover, the exit form gives forward certainty but no relief for distributions predating the rule. Issuers should be able to request post-hoc relief conditioned on filing disclosures (yes, those again); otherwise, the incentive is simply to exit and skip them.
DeFi wasn't a failure, it simply targeted the wrong species. While humans have historically struggled with the 24/7 monitoring and complex, stressful yield farming that crypto demands, these permissionless networks perfectly fit the incoming agentic economy. Billions of AI agents will soon execute the majority of global economic transactions at machine speed, a volume and pace that traditional banks simply cannot process. As AI inevitably transforms DeFi into an automated treasury infrastructure for instant lending, borrowing, and swapping, humans can finally retire from the grueling crypto night shifts. The winning strategy is to stop trying to out-trade the bots and instead own the base-layer blockchain networks. By holding the underlying infrastructure, investors can capture the immense value generated by this non-stop machine economy without having to operate at its speed.
Crypto lending has rallied 46.7% over the past week, making it the strongest sector tracked by Blockworks Research, yet Maple has been left behind. Since September 2025, Maple’s deposits have grown 69% to $4.9B and outstanding loans have risen 78% to $1.8B, while SYRUP is down 52%. Distribution is also widening through Robinhood and Kraken, while Ethena could become a sizeable source of institutional lending demand. This report examines what the market may be missing, what needs to change for earnings to grow again and whether wider distribution and rules-based buybacks are enough to bring SYRUP back into the spotlight.
